RCRA Corrective Action

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RCRA Corrective Action

Historical activities at permitted, interim status, and illegal RCRA treatment, storage or disposal facilities (TSDFs) have typically resulted in releases of hazardous waste or hazardous constituents into environmental media. The RCRA Corrective Action program, under the Hazardous and Solid Waste Amendments (HSWA) to RCRA, is a comprehensive cleanup program designed to investigate and, where necessary, remediate releases of hazardous waste or hazardous waste constituents from solid waste management units (SWMUs) at RCRA facilities on a site-wide basis. By the year 2020, EPA’s goal is to have completed implementing final remedies at all facilities requiring RCRA Corrective Action. There are a total of 3,746 facilities across the country for which these ambitious goals apply.

Cox-Colvin has been successfully completing RCRA Corrective Action projects since the firm’s inception in 1995; our experience in the Midwest is unparalleled. We have extensive experience guiding our projects through every phase of the traditional RCRA Corrective process as well as the latest post-reforms process under the 2020 RCRA Corrective Action Initiative. We have conducted Corrective Action under various statutory authority using a multitude of mechanisms including Orders, RCRA installation and operation permits, RCRA Corrective Action only permits, and formal and informal facility lead arrangements. We have trained staff from nearly every TSDF in the Midwest and many at Ohio EPA and the office of the Ohio Attorney General. We are routinely invited to speak to the Ohio State Bar Association and others on the subject.

RCRA Corrective Action services include:

  • RCRA Facility Assessment (RFA), Release Assessments, RCRA Facility Investigation (RFI), Corrective Measures Study (CMS), and Corrective Measures Implementation (CMI)
  • Description of Current Conditions Report
  • Environmental Indicators
  • Interim Measures
  • Presumptive Remedies
  • Targeted data collection and result-based approaches
  • Negotiation and implementation of standard and streamlined orders
  • Performance-based process including current conditions reports and conceptual site models
  • Exit Strategies and Corrective Action completion
  • Meeting the 2020 goals